Flawless Scalp Micropigmentation, including our subsidiaries and affiliates (collectively, “Flawless SMP”, “we”, “our”, “company” or “us”), puts great efforts in making sure that the personal data we process is stored securely and used properly, and that our data practices are accurately communicated to our users and prospective users (collectively “you” or “your”).

We offer a number of web and physical services, allowing you access to our rich products and services, including but not limited to, videos, audio files, e-books/PDFs, online courses/tutorials, photos/images, video originals, remakes, profiles online coaching or physical training, for any or all purposes, including but not limited to, trading and commerce. This Privacy Policy is our general policy which covers our processing activities on our Website.

This Privacy Policy (“Policy” or “Privacy Policy“) describes how we collect, store, use and disclose the following types of personal data:

“Prospect Data” or “Prospect(s)” concerning individuals who visit, use or engage with our website, blogs or other similar forums, online ads and content, surveys, emails or other communications under our control.

“User Data” concerning individuals (“Users”) who subscribe to our services (together the “Services”).

“Personal data” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Specifically, this Privacy Policy describes our practices regarding

1. Data Collection
2. Data Uses
3. Data Location
4. Data Retention
5. Data Security
6. Data Sharing
7. Cookies and Tracking Technologies
8. Communications
9. Data Subject Rights
10. Roles and Responsibilities
11. Additional Information and Contact Details

 

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. You are not legally required to provide us with any personal data and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data or to have it processed by us or any of our Service Providers, please avoid any interaction with us or any use of our Services.

• DATA COLLECTION

The data we process regarding our Prospects and Users is typically collected and generated through automatic means, directly from you, through your subscription to and interaction with us or with our Services; from our Users; or through third-party services, social media, analytics tools, events we organize or take part in, and other business initiatives.

Such data may include:

• Account information: e-mail address, name, user name, nickname, date of birth, gender, social media accounts, subscription status (including a token indicating payment of the subscription and payment method) and additional optional information such as profile photo and hashed password or other information used for authentication and access control.

 

By doing using our services, you provide us with information connected to such an account which may also include your name, profile picture, friends list, your social media provider identifiers, followers, language preferences, demographic data, location, account ID number/token, and email address. Please note that we do not have control over how any third party uses or discloses the personal data it collects about you.

 

• Services usage information: connectivity, technical and aggregated usage data, user agent, IP addresses, device data (such as type, OS, device ID, browser version, locale and language settings used), access times and dates logs, communication and performance logs, session recordings, issues and bugs, and the cookies and pixels installed or utilized on your device.

 

• Direct interactions and communications: messages, comments, feedback (e.g., internal communications), as well as correspondence with us (e.g., for user enablement, support and training purposes), including chats, surveys, calls and video recordings, transcriptions, and analyses thereof, and any other data you choose to provide or upload via the Services or in the context of the interaction with one of our customer experience representatives;

 

• DATA USES

We process the personal data described as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining, improving and advertising our Services. These include understanding how our Services are used, and how our Services, campaigns and other activities are performing; gaining insights which help us dedicate our resources and efforts more efficiently; marketing, advertising and selling our Services; providing customer service and technical support to our users and customers; and protecting and securing our Services, ourselves and the entities and individuals we engage with.

Please note that if you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing personal data in the manners described in this Policy (in general, or specifically with respect to the types of personal data you expect or elect to be or have processed by or via the Services), your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed herein. If you wish to revoke such consent, please contact us at info@flawlesscalp.com.

We do not sell your personal information

Specifically, we use your data for the following purposes:

 

1. To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services or for any other purpose;

 

2. To create aggregated data, anonymized or pseudonymized data and/or De-identified Data;

 

3. To enrich the content and improve the features available within the Services – this includes the use of third-party apps that allows us to record user journeys and session and create heatmaps. User content won’t be tracked;

 

4. To authenticate the identity of our Users, and to allow them to access our Services

 

5. To provide visitors to our Websites and our Users assistance and support

 

6. To evaluate and develop new features, technologies, and improvements to the Service

 

7. To perform, facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications

 

8. To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences

 

9. To contact our Website and Apps visitors, Users and Customers (whether existing or prospective) with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them

 

10. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity

 

11. To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services or for any other purpose

 

12. To comply with applicable laws and regulations.

 

DATA LOCATION

We and our authorized Service Providers maintain, store and process personal data in the various locations we operate around the globe as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Flawless SMP, its affiliates and Service Providers are each committed to protect personal data in accordance with this Privacy Policy, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data may be transferred.

DATA RETENTION

We retain your personal data for as long as it is reasonably necessary to provide you with our Services and to maintain and expand our relationship; to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (e.g. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with applicable laws and regulations. Please note that for many of our Services, Users may not use an App for a certain amount of time and still expect us to retain their personal data, such as their account information and photos. Therefore, we will generally retain your personal data for as long as necessary and permissible under the law.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at info@flawlesscalp.com.

Please also note that we do not retain your payment information, as it is transferred directly to the relevant Service Provider. We only retain a token of such payment information (which cannot be used to re-identify you) and the chosen payment method.

 

DATA SECURITY

We implement appropriate technical, organizational, and security measures to reduce the risks of damage to (or loss of) information, or any unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal data, it is not guaranteed, and you cannot expect that the Services will be immune to information security risks or attacks. Also, as the security of information depends in part on the security of the computer, device or network you use to communicate with us, and the security you use to protect your user IDs and passwords. Please make sure to take appropriate measures to protect this information.

 

DATA SHARING

Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our Services.

Service Providers: we engage selected third-party entities to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), internet service providers, operating systems and platform, data analytics services, marketing and advertising services, data and cyber security services, fraud detection services, billing and payment processing services, shipping and handling services, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems; and our business, legal, financial and compliance advisors (collectively, “Service Providers“). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating, supporting and enhancing our Services, and may only use it for such purposes.

Third-Party Websites and Services (“Vendors”): The Application may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated to us. Once you have used these links to leave the Application, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Application.

Protecting Rights and Safety: we may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Flawless SMP, our Prospects, Users, or any members of the general public.

Flawless SMP Subsidiaries and Affiliated Companies; Change of Control: we may share personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should we or any of our subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, or will be considered or found eligible for a governmental grant and/or a potential investment, personal data may be shared with the parties involved in such an event. If we believe that such event might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

Additional Sharing: we may share your personal data in additional ways, pursuant to your request or explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and/or anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

COOKIES AND TRACKING TECHNOLOGIES

We may use cookies, tracking pixels (also known as clear GIFs and web beacons) and other technologies for performance which are used to anonymously track the online usage patterns of users of the Services and in order to provide you with a better experience. In addition, we may also use tracking pixels in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. This information allows for more accurate reporting and improvement of the Services. We may share non-identifiable/aggregated extracts of such information with our partners for our legitimate business purposes.

Cookies: cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session – these are the “session cookies”. Some last for longer periods and are called “persistent cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools. Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.

Google Analytics: we use Google Analytics to collect information about the use of our Services. Google Analytics collects information such as how often you visit the Services, which pages you visited when doing so, and which other sites they used prior to coming to our Services. We do not merge the information collected through the use of Google Analytics with personally identifiable data. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy.

COMMUNICATIONS

We engage in service and promotional communications, through e-mail, phone, SMS and notifications.

Service Communications: we may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services (such as billing issues, login attempts or password reset instructions, alerts and notifications concerning anomalies detected by our Services, abandoned cart emails, surveys, etc.). You can control your communications and notifications in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use.

Notifications and Promotional Communications: we may also notify you about new features, additional offerings, events, webinars, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., SMS, phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms. Furthermore, if you contact us with an inquiry, we may respond with promotional emails relating to your inquiry. For example, if you contact us with an inquiry about a feature you would like to see on one of our Services, we will use your Contact Information to later inform you once our Services have been updated to include features similar to those you inquired about or other features you may be interested in. In order to control your notifications settings- please follow the instructions included in the promotional communications sent to you. If you do not wish to receive such communication, you may also notify us by sending an e-mail to:  info@flawlesscalp.com or opt-out of these email updates by following the unsubscribe link located at the bottom of the email.

DATA SUBJECT RIGHTS

Individuals have rights concerning their personal data. If you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (GDPR), or the CCPA, such as the right to request access, rectification, or erasure of your personal data held with Flawless SMP, your right to restrict or object to such personal data’s processing, or to port such personal data – please contact us by e-mail at: info@flawlesscalp.com. Please be advised that deleting your personal data stored with us will adversely affect your use of our Services.

Should you ever decide to delete your Account, you may do so by emailing info@flawlesscalp.com or by clicking on the delete account option in the App settings. If you terminate your Account, any association between your Account and personal data we store will no longer be accessible through your Account. However, given the nature of sharing on certain Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Please also note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request). We may redact from the data which we will make available to you, any personal data related to others.

ADDITIONAL INFORMATION AND CONTACT DETAILS

Updates and Amendments: we may update and amend this Privacy Policy from time to time by posting an updated version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via Services. After such notice period, all amendments shall be deemed accepted by you if you continue to use the Services.

External Links: while our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third-parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.

Questions, concerns or complaints: if you have any comments or questions regarding our Privacy Policy or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by us, you can contact us at info@flawlesscalp.com.

 

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Flawless Scalp Micropigmentation

5890 Fraser Street, Vancouver, BC V5W2Z5

Canada.

Updated May 2, 2022